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The HC rejected the review petition challenging its previous order treating the ITR under Section 139 as "non-est." The Court held that not answering a substantial question regarding the applicability of specific clauses of Section 158-BB did not constitute grounds for review, as this point was left open for the Appellate Tribunal to determine after remand. The Court found no error apparent on the face of the record in its earlier judgment that would justify exercise of review jurisdiction, despite the petitioner's argument about double jeopardy between regular proceedings and block assessment proceedings. The Court distinguished between the scope of review proceedings and statutory appeal, concluding that the effect of its order on subsequent proceedings would be addressed in the connected Income Tax Appeal.
The HC rejected the review petition challenging its previous order treating the ITR under Section 139 as "non-est." The Court held that not answering a substantial question regarding the applicability of specific clauses of Section 158-BB did not constitute grounds for review, as this point was left open for the Appellate Tribunal to determine after remand. The Court found no error apparent on the face of the record in its earlier judgment that would justify exercise of review jurisdiction, despite the petitioner's argument about double jeopardy between regular proceedings and block assessment proceedings. The Court distinguished between the scope of review proceedings and statutory appeal, concluding that the effect of its order on subsequent proceedings would be addressed in the connected Income Tax Appeal.
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